Breach filing
ArchivedSmith, Gambrell & Russell LLP: 220,000 individuals, Jul 2024.
Smith, Gambrell & Russell LLP reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 9 July 2024. The filing records the organisation as a business associate in Georgia and lists 220,000 individuals affected, which makes it the 22nd largest of the 226 Georgia filings on the register and the 81st largest of the 741 filings submitted nationally in 2024. Among the 17 Georgia filings made in 2024 it ranks 3rd.
Individuals affected
220,000
As reported to HHS
Modelled cost (IBM 2025)
$35.2M
Upper bound, method shown
Rank in GA
22nd
of 226 Georgia filings
Rank in 2024
81st
of 741 filings nationally
Section F.1 / The filing
As posted by HHS OCR
Every value below is the portal's own field for this filing, plus its rank within the register.
- Covered entity type
- Business Associate
- Individuals affected
- 220,000
- Breach submission date
- 9 July 2024
- Submission year
- 2024
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Georgia (GA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Georgia by size
- 22nd of 226
- Rank in 2024 nationally
- 81st of 741
- Georgia median filing
- 5,232 individuals
- Register id (derived)
- GA-20240709-smith-gambrell-and-russell
Section F.2 / In context
Where this filing sits in Georgia and in 2024
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 143 of the 226 Georgia filings (63%) and on 83% of all filings submitted in 2024. Network Server appears on 46% of Georgia filings.
A business associate is recorded as present on the filing, as it is on 34% of Georgia filings. At 220,000 individuals the breach is 42 times the Georgia median filing of 5,232 and 55 times the national median of 4,000 across all 7,884 filings. It is one of 801 filings of 100,000 or more individuals.
As of 28 August 2026 the case is listed in the HHS OCR breach portal archive. OCR's closing summary of the case is reproduced in full below.
Georgia's breach notification statute (Ga. Code 10-1-912) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: no general AG requirement (reporting agencies at 10,000+ residents). The HIPAA Breach Notification Rule ran alongside it: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery, which is the clock that put this filing on the portal.
Multiplying 220,000 individuals by IBM's $160 customer-PII cost per record (Cost of a Data Breach 2025, the figure the site's calculator uses) gives a modelled $35.2M; the 2026 edition's $192 gives $42.2M. Both are modelled estimates with the method shown, not costs disclosed by Smith, Gambrell & Russell LLP. Because the filing is above the roughly 100,000-record range in which the per-record figure is reliable, the result is an upper bound, not an estimate: fixed costs are spread across far more records at this scale.
Section F.3 / OCR closing summary
The portal's archived description, in full
Written by the Office for Civil Rights when the case was closed and reproduced verbatim from the HHS export.
The business associate (BA), Smith, Gambrell & Russell, LLP, reported that it experienced a hacking incident that affected the protected health information (PHI) of 4,688 individuals. The PHI involved included demographic, clinical, and financial information. The BA notified HHS and affected individuals. In response to the breach, the BA issued media, substitute and individual notice, and implemented additional administrative, technical, and security safeguards.
Section F.5 / Modelled cost
220,000 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$35.2M
220,000 x $160
IBM 2026 customer PII, $192 per record
$42.2M
220,000 x $192
Method: individuals affected, as reported by Smith, Gambrell & Russell LLP to HHS, multiplied by IBM's customer-PII cost per record (Cost of a Data Breach 2025 Figure 6 and the 2026 edition). No cost has been disclosed by the entity for this filing; the figure is a planning estimate, not a fact about the breach. IBM's per-record figures come from mid-volume breaches and IBM cautions against applying them to breaches involving millions of records; the site's per-record page explains where the multiplication holds and where it breaks down.
Context: IBM's average cost of a healthcare breach is $6.64M in the 2026 report ($7.42M in 2025); the global average across all sectors was $4.44M in 2025.
Cost per record: method and limits / Healthcare breach cost, IBM 2026
Section F.6 / Notification clock
Georgia statute and the HIPAA rule
State notification statute
Georgia: Ga. Code 10-1-912
Personal Identity Protection Act
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- No general AG requirement (reporting agencies at 10,000+ residents)
- Private right of action
- No: No direct individual lawsuits for notification failures
- Penalty
- No explicit statutory penalties; possible exposure under the Fair Business Practices Act
The HIPAA Breach Notification Rule runs alongside the state statute: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.
Section F.7 / Peer filings
Georgia filings closest in size
Neighbours by size rank among Georgia filings in 2024, topped up from other years where 2024 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Young Consulting LLC | Business Associate | 961,003 | 11 Sep 2024 | |||
| CF Medical | Business Associate | 242,200 | 26 Sep 2024 | |||
| The Medibase Group, Inc. | Business Associate | 117,957 | 5 Jul 2024 | |||
| Aveanna Healthcare | Healthcare Provider | 65,482 | 15 Mar 2024 |
Index / Companion schedules
13 HHS breach register
→Hub: every filing, by state, year and entity.
04 Biggest breaches
→Mega-breaches with primary-source cost figures.
Industry / Healthcare
→IBM 2026: $6.64M average, 13 years at #1.
Regulation / HIPAA penalties
→OCR enforcement tiers and the 60-day rule.
11 50-state laws
→Deadline, AG threshold and penalties per state.
Cost / Per record
→Where the per-record model is reliable.
Provenance
Source: U.S. Department of Health and Human Services, Office for Civil Rights, Breach Portal (breaches affecting 500 or more individuals), retrieved 2026-08-28. Public domain. Individuals affected and dates as reported by the covered entity.
Portal: ocrportal.hhs.gov breach report. Statutory basis: HITECH Act section 13402(e)(4): the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. Breaches affecting fewer than 500 individuals are reported to OCR annually and are not posted, so they are not on this register. Status wording follows the portal's two tabs ("Cases Currently Under Investigation" and "Archive") as of 28 August 2026; a filing moves to the archive when OCR closes the case. Modelled costs on this site are a method applied to the reported count, using IBM Cost of a Data Breach per-record figures, and are never a cost disclosed by the entity. This row: hhs-breach-archive__2026-08-28.csv, export row 856.
Corrections: if you represent a listed entity and the portal row has been amended, email [email protected] with the portal entry and we will re-pull the export.